In this privacy policy, we explain how Sijoitusasuntovahti Oy processes the personal data of its customers, contacts, and website users. This privacy policy has been prepared in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (GDPR).
Updated on October 27, 2026.
1. Data Controller and Contact Information
Sijoitusasuntovahti Oy
Business ID 3354444-2
Sorronkuja 3, 04410 Järvenpää
For any questions or requests regarding this policy or the processing of personal data, please contact:info@horisonttigroup.com
2. What personal data do we process?
We process only the data we need for each of the purposes described below.
- Basic and contact information:name, phone number, email address, mailing address, and—for corporate customers—the contact person’s title and organization.
- Information related to customer identification:personal identification number, identification document details, and other information required by the Anti-Money Laundering Act when we act as a broker in a transaction.
- Assignment and Customer Relationship Information:information about properties, assignments, offers, and transactions; contracts; billing and payment information; notes from customer meetings; and other communications related to customer relationships.
- Information from apartment showings:the names and contact information of those who attended the showing.
- Marketing information:marketing permissions and opt-outs, newsletter subscriptions, and information about which topics and subjects interest you.
- Information regarding website usage:IP address, browser and device specifications, cookie identifiers, actions taken on the pages (e.g., submitting a form), and information about which ad led you to the site.
- Social media information:public profile information when you interact with us via social media.
3. Where does the information come from?
We obtain information primarily from you: through forms on our website, via email, by phone, through social media, during property showings, at client meetings, and from contracts.
In addition, data may be collected:
- from the website using cookies and similar technologies (see Section 5)
- from advertising platforms, when you arrive at the site via an ad
- from public sources, such as the commercial register, company websites, and directory services (company contacts)
- from official registries and from the counterparty to the assignment, when necessary for the performance of the assignment
4. Purposes of Use and Legal Bases
There is a legal basis for each type of data processing in accordance with the General Data Protection Regulation. Below, we explain how we use the data and on what basis.
| Purpose | Legal Basis |
|---|---|
| Handling brokerage, appraisals, and other assignments; maintaining client relationships; billing and collections | Contract or actions preceding the contract |
| Processing the information of the other party to the transaction (e.g., the buyer or tenant) for the purpose of completing the transaction | A Legitimate Benefit |
| Know Your Customer (KYC) and Anti-Money Laundering (AML), Accounting, and Other Legal Obligations | Legal obligation |
| Information on participants in apartment viewings for the purpose of preventing and investigating crimes and misconduct | A Legitimate Benefit |
| Responding to inquiries and providing information about properties to interested parties | Legitimate interest or pre-contractual measures |
| Electronic direct marketing to consumers and newsletters | Consent |
| Marketing to corporate client contacts and existing customers | A Legitimate Benefit |
| Website analytics and the targeting and measurement of advertising using cookies | Consent |
| Website Functionality and Security (Essential Cookies, Logs) | A Legitimate Benefit |
| Drafting, filing, or defending legal claims | A Legitimate Benefit |
When processing is based on a legitimate interest, we have determined that our interest is balanced against your rights. You may always object to such processing (see Section 10). You may withdraw your consent at any time; this will not affect the lawfulness of the processing carried out prior to the withdrawal.
Providing information is voluntary. However, without certain information—such as the identification details required by the Anti-Money Laundering Act—we cannot process your request.
5. Cookies and Website Tracking
Cookies are small text files that are stored in your browser when you visit a website. We use cookies and similar technologies, such as tracking pixels, for four purposes.
- Essential:website functionality, security, and remembering your cookie preferences. These are always enabled.
- Functional:for example, the functionality of forms and embedded content.
- Analytics:statistical data on how the site is used (Google Analytics).
- Advertising:targeting ads and measuring which ads drive traffic and generate leads.
We use non-essential cookies only if you give your consent via the cookie banner on the website. You can change your preferences or withdraw your consent at any time in the cookie settings at the bottom of the page.
The analytics and advertising services we use
| Service | Purpose |
|---|---|
| Google Analytics (Google) | Website Usage Statistics and Development |
| Google Ads (Google) | Ad Targeting and Measuring Performance |
| Meta Advertising (Facebook and Instagram) | Ad Targeting and Measuring Performance |
| LinkedIn Advertising | Ad Targeting and Measuring Performance |
| ChatGPT Ads (OpenAI) | Measuring the effectiveness of ads displayed on ChatGPT |
OpenAI tracking pixel.When you arrive at the site via our ad displayed in ChatGPT, a click identifier is attached to the link. OpenAI’s tracking pixel stores this in the __oppref cookie in your browser and sends OpenAI information about your actions on the site, such as loading a page or submitting a contact form. This allows us to see which ads are effective. The pixel is only active if you have accepted advertising cookies.
Advertising platforms may also process the information they receive through cookies for their own purposes, in accordance with their own privacy policies. An up-to-date list of the cookies used on the site and their expiration dates can be found in the site’s cookie settings.
More information about service providers' privacy policies:
6. Recipients and Processors of Data
We do not sell or rent personal information. Information may be disclosed or provided to the following parties for processing:
- Service providers who process data on our behalf:for example, customer relationship management (CRM), email marketing, website maintenance and hosting, cookie consent management, accounting, and IT services. They may process data only in accordance with our instructions and under the terms of a data processing agreement.
- Advertising and analytics platforms:Google, Meta, LinkedIn, and OpenAI, as described in Section 5, once you have given your consent.
- Parties to the Assignment:Necessary information for the counterparty to the sale or lease, the property manager, banks, and other parties involved in the transaction, as agreed.
- Group:Companies belonging to the same group may use customer data for customer service, customer relationship management, and marketing purposes to the extent permitted by law.
- Authorities:to fulfill legal obligations, such as those to the Financial Intelligence Unit or the tax authorities.
7. Transfers Outside the EU and the EEA
We process data primarily within the EU and the EEA. Some of our service providers, such as Google, Meta, LinkedIn, and OpenAI, may also process data in the United States or elsewhere outside the EU and the EEA.
In such cases, we ensure that the transfer is based on grounds that comply with the General Data Protection Regulation. The legal basis is either a European Commission decision on the adequacy of data protection (in the United States, the EU-U.S. Data Privacy Framework, provided the recipient has committed to it) or standard contractual clauses approved by the Commission, along with the necessary additional safeguards. For more information on the safeguards for these transfers, please contact us.
8. Retention Periods
We retain data only for as long as is necessary for the original purpose or as required by law. After that, the data is deleted or anonymized.
| Information | Shelf Life |
|---|---|
| Documents Related to Assignments | At least 5 years from the end of the assignment (Real Estate Brokerage Act); longer only if necessary due to legal claims |
| Information related to knowing the customer | 5 years from the end of the customer relationship or business transaction (Money Laundering Act) |
| Accounting documents, such as invoices | 6 years from the end of the fiscal year (Accounting Act) |
| Participant Information for Apartment Showings | The duration of the assignment and the retention period for its documents |
| Information on potential customers and people who have contacted us | 3 years since the last contact |
| Marketing Permissions and Newsletter Subscription | Until you withdraw your consent or cancel your subscription |
| Marketing Restrictions | As long as the ban is in effect, so that we can comply with it |
| Cookies | For information on individual cookies, see the website's cookie settings |
9. Information Security
We protect personal data using appropriate technical and organizational measures. Access to the data is limited to those employees and service providers whose duties require it, and they are bound by a duty of confidentiality. The systems are protected by usernames and passwords, and data transmission on the website is encrypted.
10. Your Rights
You have the right to:
- to access your personal information—that is, to know what information we process about you and to obtain a copy of it
- correctincorrect information and fill in missing information
- request that your data be deleted, unless we have a legal obligation to retain it
- restrict processingin certain situations
- object to processing based on our legitimate interest
- prohibit direct marketingat any time
- Withdraw your consent, for example, by adjusting the cookie settings on the website for cookies, or by clicking the unsubscribe link in the newsletter
- transfer datafrom one system to another when the processing is based on consent or a contract
Please send your request to info@horisonttigroup.com. We may ask you to verify your identity. We will respond to your request within one month at the latest.
If you believe that we are processing your data in violation of the law, you may file a complaint with the Office of the Data Protection Ombudsman (tietosuoja.fi).
11. Automated Decision-Making and Profiling
We do not make decisions about you that have legal effects or other significant consequences based solely on automated processing. We may tailor marketing and advertising based on your interests and your use of the site, provided you have given your consent.
12. Changes to the Summary
We will update this statement as our operations or the law change. The most current version is always available on our website, and the date of the most recent update is listed at the beginning of the document.